Sambo's Restaurants maintained a uniform grooming policy concerning each of its more than one thousand establishments nationwide. The policy forbade restaurant managers and other restaurant personnel to wear facial hair, with an exception for a neatly trimmed mustache. Sambo's has consistently enforced this grooming policy since the restaurant chain's inception in 1957. Grooming standards similar to Sambo's were common in the restaurant industry. Sambo's believes that the grooming policy reflected the restaurant's public image as a family-oriented business where food was served under sanitary conditions.

Mohen S. Tucker was a member of the Sikh religion. The practice of Sikhism forbade the cutting or shaving of facial hair and also required the wearing of a turban that covered the head. In accordance with the dictates of his religion, Tucker wore a long beard. Tucker applied for a position as a Sambo's restaurant manager. While filling out the application, he was informed of Sambo's grooming policy, which would require that he shave his beard or be denied the position. Tucker informed Sambo's that it was against his religion to shave his beard. Sambo's responded that no exceptions were allowed under the grooming policy for religious reasons and denied his application.

Tucker brought a court action through the EEOC, claiming that Sambo's had violated Title VII by refusing to accommodate his religious practice. Sambo's denied any religious discrimination.

What standard of review should be employed to decide this case? What factors will be relevant? Decide the case. [EEOC v.
Sambo's of Georgia, Inc., 27 FEP 1210 (N.D. Ga.)]